Whistleblowing

WHAT IS A WHISTLEBLOWING REPORT:
is the communication - in written or oral form, through internal or external reporting channels - of crimes, irregularities or violations of national or European Union regulatory provisions detrimental to the integrity of the companies Ambiente S.p.A., B.Energy S.p.A., Planetaria S.r.l. and Greenenergy Holding S.p.A. (hereinafter also "Greenenergy Group companies") and occurred in the working context of these companies.

WHAT YOU CAN REPORT:

• significant illicit conduct pursuant to Legislative Decree 231/2001, or violations of the company's organization and management models;
• administrative, accounting, civil or criminal offences;
• offenses that fall within the scope of application of European Union or national acts relating to the following sectors: public procurement; financial services, products and markets and prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental Protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; protection of privacy and protection of personal data and security of networks and information systems;
• acts or omissions detrimental to the financial interests of the Union;
• acts or omissions relating to the internal market;
• acts or behavior that frustrate the object or purpose of the provisions set out in Union acts.

WHO CAN MAKE A REPORT:

• employees of public administrations, as well as employees of independent administrative guarantee, supervisory or regulatory authorities;
• employees of public economic bodies, private law bodies subject to public control pursuant to art. 2359 c.c., of companies in house, public law bodies or public service concessionaires;
• the subordinate workers of each Group company (e.g.: fixed-term, permanent, apprenticeship, temporary work, occasional services, etc.);
• self-employed workers as well as holders of a collaborative relationship (e.g. continuous and coordinated work of a non-subordinate nature), who carry out their work for entities in the public sector or for each company of the Group;
• workers or collaborators who carry out their work for entities in the public sector or for each Group company that supply goods or services or carry out works for third parties;
• freelancers and consultants who work for public sector entities or for each Group company;
• volunteers and interns, paid and unpaid, who work for public sector entities or for each Group company;
• shareholders and people with administrative, management, control, supervisory or representation functions, even if these functions are exercised on a purely de facto basis, by entities in the public sector or by each company of the Group.

The protection of the aforementioned reporting persons also applies if the report, the complaint to the judicial or accounting authority or the public disclosure of information occurs in the following cases:

• when the legal relationship has not yet begun, if the information on the violations was acquired during the selection process or in other pre-contractual phases;
• during the probationary period;
• following the dissolution of the legal relationship if the information on the violations was acquired during the relationship itself.

WHICH INTERNAL REPORTING CHANNELS

A) Communication in written form:

• compilation of Whistleblowing Report Form present in the CONTACTS section of the website of each of the Group Companies;
• sending e-mails to members of the Office (avv.stefanosarno@gmail.com; gieffeconsultingsas.gaetano@gmail.com; studio.febbraio@libero.it) bearing the subject “Whistleblowing reporting”;
• in a sealed envelope"to the attention of the Whistleblowing Report Management Office", to be delivered short manuals to one of the members of the Office itself or to be sent by registered mail with return receipt to the address of their professional office;

B) Oral communication:

• via telephone line or voice messaging systems, by sending the communication to the users of the members of the Office itself (339 14 85 240; 338 67 50 325) with the subject "Whistleblowing Report";
• by request to the Office (made by telephone, e-mail or personally to one of the members) for a direct meeting, set within seven days of receipt of the request.

WHICH EXTERNAL SIGNALING CHANNELS

The reporting person may make an external report if, at the time of its submission, one of the following conditions applies:

1. There is no provision, within the Company concerned, for the mandatory activation of the internal reporting channel or this, even if mandatory, is not active or, even if activated, does not comply with the provisions of Article 4 of the Legislative Decree 24/2023 on internal reporting;
2. the reporting person has already made an internal report pursuant to art. 4 of Legislative Decree 24/2023 and the same was not followed up;
3. the reporting person has reasonable grounds to believe that, if he/she made an internal report, it would not be followed up effectively or that the same report could lead to the risk of retaliation;
4. the reporting person has reasonable grounds to believe that the violation may constitute an imminent or obvious danger to the public interest.

Reporting can also take place through one of the following channels:
A) communication in written form:

• by forwarding the report through the appropriate section on the A.N.A.C. website https://www.anticorruzione.it/-/whistleblowing
• sending certified e-mail to the address protocollo@pec.anticorruzione.it

B) oral communication:

• through telephone lines or voice messaging systems to the number +39 06 62289571
• at the request of the reporting person, through a direct meeting set within a reasonable time. Further contacts ofA.N.A.C. they are available on https://www.anticorruzione.it/